PRIVACY POLICY

CATEGORIES OF INFORMATION WE COLLECT

We collect nonpublic information about you from the following sources:

*Information we receive from you on applications or other forms; such as, your name, address, social security number, assets and income;;

*Information about your transactions with us, our affiliates, or others; such as your account history and your investments; and

*Information you provide us during meetings.

CATEGORIES OF INFORMATION WE DISCLOSE

We do not disclose any nonpublic personal information about our investors or former investors to anyone, except as required by law (i.e. a subpoena or the IRS).

We restrict access to nonpublic information about our investors and clients to those affiliates, such as our advisor and the service companies providing administrative services to us and employees who need to know that information to provide our services. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard our investor’s nonpublic personal information.

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